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Understanding the FCPA - ACC.com

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Introduction: A Robust Enforcement Climate<br />

U.S. Foreign Corrupt Practices Act (―<strong>FCPA</strong>‖) enacted in 1977<br />

Three-fold increase in enforcement activity at DOJ since<br />

2004<br />

Increased numbers of <strong>FCPA</strong>-dedicated attorneys in Fraud<br />

Section<br />

Approx. 50 FBI agents working on <strong>FCPA</strong> matters<br />

2007 a landmark year<br />

Largest number of DOJ & SEC enforcement actions (38)<br />

Largest <strong>com</strong>bined settlement to date ($44 million) – likely to<br />

soon be eclipsed<br />

Largest criminal penalty to date ($26 million)<br />

Approx. 100 <strong>com</strong>panies believed to be under investigation at<br />

year end<br />

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